Author: compliance 小白
Recently, the Bank for International Settlements (BIS) released Chapter 3 of its Annual Economic Report:
Anchoring trust in money: innovation beyond stablecoins
This can be understood as:Anchoring Trust in Money: Innovation Paths Beyond Stablecoins. The report was published on June 23, 2026.
From a macro-financial perspective, this report discusses the future monetary system, tokenization, and stablecoins.
But viewed from a compliance standpoint, it truly reminds us of the following:
The issue with stablecoins is not just whether their price will de-peg, but whether they can be integrated into a financial system that is identifiable, monitorable, accountable, and regulatable.
I. BIS Is Not Opposed to Technology, But Rather Asks: Where Does Trust Come From?
BIS acknowledges that stablecoins and tokenization do bring efficiency improvements, such as faster payments, programmable payments, atomic settlement, and reduced reconciliation friction. The report also points out that DLT and tokenization can place assets and funds on programmable ledgers, supporting automation and 24/7 operations.
But the core view of BIS is:
Money is not merely a technological product.
Money can serve as money not just because it can be transferred, but because it is backed by a set of institutional arrangements:
A common unit of account,
Certainty of redemption at par value,
Liquidity support,
Regulatory and legal frameworks,
And financial integrity requirements.
This is crucial for compliance professionals.
Because any new payment instrument, once entering large-scale usage scenarios, will ultimately face the same question:
Who identifies the customer? Who monitors the transactions? Who handles exceptions? Who bears the responsibility?
II. The Compliance Risks of Stablecoins Go Beyond On-Chain Anonymity
When many people talk about stablecoin risks, their first reaction is "on-chain anonymity" and "wallets are hard to trace."
But the BIS report explains it more systematically.
In the traditional financial system, banks and regulated entities bear responsibilities such as customer identification, transaction monitoring, suspicious activity reporting, and, when necessary, stopping or recalling payments. In contrast, stablecoins primarily circulate on public, permissionless blockchains, where pseudonymity, non-custodial wallets, cross-chain bridges, and mixing tools may all weaken KYC and AML/CFT controls.
This means stablecoins present not a single-point risk, but a combination of risks:
Who the customer is may not be clear;
The origin of funds may not be complete;
The purpose of the transaction may not be explainable;
After crossing chains, the path may become fragmented;
In case of problems, the responsible entity may also be unclear.
Therefore, for the compliance department, we cannot just ask:
"Is this address risky?"
We should ask more:
Why does this customer use stablecoins?
How do they move funds between stablecoins and fiat currency accounts?
Who is the counterparty?
What is the relationship between wallets, trading platforms, and payment institutions?
Is the fund flow consistent with the customer's background and business model?
III. On-Chain Transparency Does Not Equal Compliance Transparency
Stablecoin proponents often say: on-chain transactions are all public, so they are more transparent.
This statement is only half true.
On-chain data is indeed visible, but "address visibility" does not equal "identity visibility."
"Transaction path visibility" also does not equal "clear transaction purpose."
BIS also mentions that blockchain analytics firms are already supporting law enforcement agencies, and some stablecoin issuers have frozen specific on-chain addresses, which indicates that on-chain technology can indeed aid risk identification.
But BIS also emphasizes that these measures cannot replace daily, large-scale AML/CFT controls.
Real compliance is not about buying a tool, but about establishing a closed loop:
Can you identify virtual asset exposure before customer onboarding?
Can you monitor on-chain and off-chain fund flows when transactions occur?
After hitting a risk flag, can you conduct manual review and explanation?
After forming a suspicious lead, can you document, escalate, and report it?
After adjusting models and rules, can they be audited and reviewed?
Technology is just one link in the compliance chain, not compliance itself.
IV. Stablecoins Will Bring "On-Chain Risks" Back to Traditional Finance
The BIS report mentions that as of the end of May 2026, the market capitalization of stablecoins was approximately $3.2 trillion; estimated annual trading volume for 2025 was about $28 trillion, but after excluding transfers between wallets of the same entity, the actual economic significance is much lower.
These numbers illustrate one thing:
Stablecoins are already large enough to not be ignored by compliance departments;
But they are not yet mature enough to completely replace the existing financial system.
More importantly, stablecoin risks will not remain confined to the blockchain.
They will re-enter traditional financial institutions through on-/off-ramps, trading platforms, payment institutions, trade scenarios, cross-border settlements, and customer accounts.
For example:
Customers frequently use bank accounts to fund virtual asset platforms;
Corporate clients claim to conduct cross-border trade, but funds ultimately flow through stablecoin channels;
Personal customer accounts receive large influxes from strangers followed by concentrated purchases of virtual assets;
Customers explain it as "investment," "settlement," "currency exchange," but the transaction behavior does not match the income source.
These scenarios are essentially not pure "virtual asset issues," but rather customer due diligence and transaction monitoring issues that traditional financial institutions must confront.
V. Future Regulatory Direction: Not Prohibiting Innovation, But "Embedding Rules"
BIS proposes a very important direction:
Future tokenized finance should not be detached from the existing trust system. Instead, tokenization technology should be introduced into the two-tier monetary system based on central bank money and regulated institutions. From a compliance perspective, this essentially means four words: rules first. A more viable future digital financial infrastructure should embed the following into the transaction process: customer identity verification,
Pre-transaction screening,
Risk rule assessment,
Auditable data trails,
Privacy and data sovereignty protection, and Cross-institutional, cross-jurisdiction collaboration mechanisms. BIS also explicitly states that permissioned platforms, if able to embed AML/CFT pre-screening, list screening, and auditable data trails into the transaction flow, are more likely to maintain financial integrity at scale. This is also where regtech's true future value lies: not in remedial action after the fact, but in embedding risk controls into the process before payment and settlement occur.
compliance 小白 Observations
The inspiration from this BIS report for compliance professionals is not actually about "whether stablecoins are good or bad," but rather:
All new financial instruments in the future, if they wish to become mainstream payment and settlement tools, must answer compliance questions.
Who identifies the customer?
Who monitors the transactions?
Who handles exceptions?
Who bears responsibility?
Who ensures consistent cross-border rules?
If these questions remain unanswered, even the most advanced technology will only transfer risks to places that are harder to regulate.
Therefore, viewed from a compliance perspective, stablecoins are not merely a "crypto topic."
They will impact bank account monitoring, payment institution risk controls, cross-border fund flows, virtual asset access, customer risk ratings, and financial crime prevention.
The truly valuable direction for the future is not using technology to circumvent compliance,
but embedding compliance capabilities into the technological infrastructure.
Compliance is not the opposite of innovation.
Compliance is the infrastructure that determines whether financial innovation can go far.
